[elebra]

If we are refinancing a loan and using an existing mortgage, we would put the NMLS# on any NEW documents that require it. Since we are using an existing mortgage, is it ok that it might not have an NMLS# if it has some age to it?

[rcooper]

There isn’t any language that gives an exception for this type of situation, therefore, I recommend including it.

[elebra]

So you suggest that we don’t use an existing mortgage if it doesn’t have the NMLS# on it…we should file a new mortgage?

[jholzknecht]

The reg states, “For a consumer credit transaction secured by a dwelling, a loan originator organization must include on the loan documents described in paragraph (g)(2) of this section, whenever each such loan document is provided to a consumer or presented to a consumer for signature…” In your transaction Since the existing mortgage is not “provided to a consumer or presented to the consumer for signature” it appears the LO’s name and number is not needed. Different facts might result in a different answer.

[elebra]

Thank you Jack!!

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